Providers will have to caveat their emptori from now. The good people over at CMS have issued a memo that they hope will clarify the Advance Beneficiary Notice of Noncoverage (ABNs) requirements of the American Taxpayer Relief Act.

In the good ole days of say, Dec. 31, 2012, providers were merely “encouraged” by CMS to warn patients that there were therapy caps and all that.

“Now the provider/supplier must issue a valid, mandatory ABN to the beneficiary before providing services above the cap when the therapy coverage exceptions process isn’t applicable,” CMS says in the memo.